Iron Gate Security, Inc. v. Lowe's Companies, Inc., 1-15-cv-08814 (NYSD August 3, 2016, Order) (Forrest, J.)
Friday, August 5, 2016
Motion-Triggered Multimedia Indexing Patent Not Directed to Ineligible Subject Matter Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s patent for real-time indexing of multimedia data in response to detecting motion encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[T]he main thrust behind step one is to determine whether the claim moves beyond a long-understood concept or simply seeks to monopolize one by masking it through the medium of technology. . . . A court must, in other words, ask whether the claims are directed to a specific implementation to a solution to a problem. The point is not to deem ineligible any task or concept that can possibly be envisioned or performed by the human mind. . . . [O]ne could characterize a four-function calculator as an apparatus directed to the abstract idea of executing basic mathematical formulas by means of computer technology. The Court is highly skeptical that, if first invented today, such an invention would be found to be directed to an abstract idea at Alice step one based on this high-level description of the invention. It is worth reemphasizing that [Alice Corp. Pty. Ltd. v. CLS Bank International, 134 S. Ct. 2347 (2014)] is not a novelty test; it is improper to ask under Alice 'has this been done before.' That is a novelty question. . . . [I]t is clear that the [patent-in-suit] is directed to particular improvements over prior art multimedia data indexing techniques that render such data accessible in real time. At least on the face of the patent, this is a real invention designed to solve a problem, not mere implementation of the abstract idea of indexing data. . . . Where the patent explains how the claimed process improves upon prior multimedia data indexing techniques, thus enhancing a process that operates solely within the technological realm itself, the claimed invention will survive step one."